Iran Sanctions: Ship to ship transfers

The Club has been made aware of recent attempts to export crude oil from Iran in breach of sanctions. On several occasions, oil has been carried from Iran, to Kor Fakkan UAE, under documents falsely describing the cargo as having been loaded in Iraq. It has then been delivered by ship-to-ship transfer to vessels bound for countries that do not benefit from a waiver under applicable US Sanctions legislation.

Members should be aware that the Club cannot provide cover to vessels which are involved in transporting crude oil originating from Iran and in breach of sanctions. In addition to automatic cessation of insurance cover under the Club’s Rule 5V, Members and related parties may potentially face enforcement action by the US authorities for any violation of applicable sanctions.

Members involved in STS operations in the Arabian Gulf are accordingly advised to investigate carefully and exercise caution during operations. It is recommended that Members check with port agents that vessels providing cargo by means of an STS transfer did in fact load the cargo at the port stated in the cargo documentation. Members should also ensure that charter parties contain an appropriate sanctions clause.